CI-D and CI-X Frequently Asked Questions

CI-D and CI-X filings must be submitted twice a year on March 1 and September 1.

The Commission will track the facilities that do not comply with Rule 3.65.  Facilities that do not comply will go through the Commission’s enforcement process. Note that Commission Rule 3.107 sets out the minimum penalties associated with a failure to file.  The minimum penalty associated with a failure to file a CI-D or CI-X with the Commission is $1,000 and the minimum penalty associated with a failure to submit the critical customer information to your utility is $2,500.

The RRC online filing system will catch some clerical errors and notify you during the online filing process. RRC staff will also review for clerical errors and help you resolve them. You will also have the ability to edit info on your submission.

Rule 3.65 contains requirements for facilities to be designated critical mainly to increase the likelihood that the facilities will receive electric power during energy emergencies for load shed planning and power restoration purposes. Under Rule 3.65 operators are required to complete the online CI-D and/or CI-X filing process.  In addition, Critical Facility Customers must also download their CI-D filing information and provide it to their facility’s electric provider.

Rule 3.66 contains the RRC’s weatherization requirements.

Pursuant to Tex. Nat. Res. Code § 86.044, Gas Supply Chain Facilities (which are non-pipeline facilities) are subject to Rule 3.66 is they are (1) designated critical in accordance with Rule 3.65, AND (2) included on the Electricity Supply Chain Map.

Pursuant to Tex. Util. Code § 121.2015, Gas Pipeline Facilities are subject to Rule 3.66 if they (1) are on the Electricity Supply Chain Map, AND (2) directly serve natural gas electric generation facilities operating solely to provide to the electric grid for the ERCOT power region, or for the ERCOT power region and an adjacent power region.”

Only list the oil lease number.

The lease location can be denoted by the latitude and longitude of the gate entrance to the lease.

Yes. You may have multiple facilities along the same pipeline segment T-4 permit. Select all applicable facilities when filing.

Please see 16 Tex. Admin Code § 25.52(h)(1).

A searchable and downloadable list is available at this link (under Critical Natural Gas):
https://www.puc.texas.gov/industry/electric/directories/Default.aspx

Gas Leases: Provide the average daily gas production for the well from the six most-recently filed production reports (Mcf/day). Wells without six months of production reports shall average the production from the well’s production reports on file with the Commission or use the production volume from the well’s initial potential test or deliverability test if the well has not yet filed a production report.

Oil Leases: Provide the average daily gas production for the lease from the six most-recently filed production reports (Mcf/day). Wells without six months of production reports shall average the production from the well’s production reports on file with the Commission or use the production volume from the well’s initial potential test or deliverability test if the well has not yet filed a production report.

Attach a written justification in accordance with §3.65(f) to Form CI-X in support of the Form CI-X exception application. For example, you can create one PDF document that includes the Form CI-X, followed by pages that contain your written justification and evidence. The Form CI-X, written justification attachment and CI-X attachment can be filed through the RRC Online System. The written justification must include objective evidence to support it. Ensure your justification includes objective evidence to enable staff to verify your justification or your exception request will likely be denied.

For Column E: If a gas well subject to §3.65(b), provide the RRC gas ID number (6-digit) and the average daily gas production for the well from the six most-recently filed production reports (Mcf/day). Wells without six months of production reports shall average the production from the well’s production reports on file with the Commission or use the production volume from the well’s initial potential test or deliverability test if the well has not yet filed a production report.

For Column G: If an oil lease subject to §3.65(b), provide the RRC oil lease number (7-digit) and the average daily gas production for the lease from the six most-recently filed production reports (Mcf/day). Wells without six months of production reports shall average the production from the well’s production reports on file with the Commission or use the production volume from the well’s initial potential test or deliverability test if the well has not yet filed a production report.

Rule 3.65(b)(1) sets forth the criteria for determining whether a facility is critical.  If a party operates any facilities of the type listed in Rule 3.65(b)(1)(A) – (H), then those facilities are designated as critical during an energy emergency.  For gas wells (Rule 3.65(b)(1)(A)), wells that produce in excess of 250 Mcf/day, are considered critical.  For oil leases (Rule 3.65(b)(1)(B)), leases producing casinghead gas in excess of 500 Mcf/day, except for EOR projects provided the EOR project consumes more energy than it produces calculated by comparing the amount of electricity used to the amount of gas produced both in Million British Thermal Units (MMBTU) are considered critical. Please see Rule 3.65(a)(3) for the six-month method to calculate a well or lease’s production amounts for purposes of the rule. 

If a well does not have six months of production, then per the instructions for Form CI-D, the operator shall average the production from the well’s production reports on file with the Commission or use the production volume from the well’s initial potential test or deliverability test of the well has not yet filed a production report.

Yes. It does not matter whether a facility requires electricity to operate or not—they are subject to the requirements of §3.65 if they operate a facility of any of the types listed in Rule 3.65(b)(1)(A)-(H), which are defined as Critical Gas Suppliers. Critical Gas Suppliers file Form CI-D and CI-D Attachment with the RRC.

However, you will not need to fill out the “green section” of the “Acknowledge” tab, when filing your CI-D submission.

No. If you have a facility such as a gas well or an oil lease that is currently not in production, you do not need to include that facility when filing CI-D.  In the event you return the facility to production, it may be necessary for you to add it to the next filing following its return to production, to the extent its production exceeds the volumetric thresholds set forth in Rule 3.65(b)(1).

No.  If you intend to apply for an exception, only file CI-X.  If you are seeking an exception for more than one facility, click on, “Click to include in filing” for each facility you wish to include in your CI-X filing.

Yes. Using the text box on the CI-X “Acknowledge” tab, provide a written justification in accordance with §3.65(e). The written justification must include objective evidence as support so that staff can verify your justification. Otherwise, your exception request will likely be denied. You can also click the “Choose PDF Document File (Optional)” button below the text box and upload any supporting documentation (PDF format).

Yes. If it is your first time filing CI-X you will need to follow the online instructions for submitting the $150.00 filing fee. This is a one-time fee – you do not have to pay it every time you file CI-X.

You are required to reapply each filing session, for each facility, even if it was previously granted an exception.  Please include with your materials an explanation that the facility was previously granted an exception and whether the circumstances of the facility have changed.  You must still include a justification and evidence when filing CI-X. You are not required to pay the fee again.

Yes.

For a utility located in a competitive area, this is the unique account number that identifies your facility.

The ESI-ID number is typically found on your electricity bill.  If not, you will need to contact your utility provider for this information.

A Facility Report can be generated in the Dashboard under the tab “Generate Filing Report”. Please be advised that this report represents the facilities that will auto-populate when filing the Form CI-D/CIX. The operator is responsible for editing and/or adding any facilities subject to the filing requirement.

Currently, Gathering Lines are not included in the filing requirement.  However, off-lease components on gathering systems such as Compressor Stations are subject to the filing requirement.

The CI-D/CI-X filing requirements outlined in Rule 3.65 are separate from facilities being included on the supply chain map (Rule 3.66). ALL natural gas pipelines, local distribution lines, and any critical components are required to be filed.

The system will only auto-populate facilities identified during a subset of time. Operators are responsible for including any new facilities acquired on or before the filing deadline by selecting “Add New Facility”.

Rule 3.65 requires a CI-D/CI-X filing for ALL Saltwater Disposal Wells, regardless of oil and/or gas production totals.  The only exception to this requirement is Secondary Recovery Injection Wells (must be classified as such with RRC) that are not tied to a critical oil lease or gas well.

Due to circumstances frequently changing in the oil and gas industry, we must ensure facilities previously approved for CI-X remain eligible. Per Rule 3.65, beginning in 2023, the Form CI-X “exception” application shall be filed by March 1 and September 1 of each year. 

Plugged SWD’s with an *approved* W-3 on file are not subject to the filing requirement. If you have facilities that auto-populate during the filing process that you believe are NOT subject to the filing requirement, please reach out to our office and staff will review those facilities.

If the P-5 name change AND the transfer of all facilities are not finalized prior to the CI-D/CI-X filing deadline, then you are required to file under the original P-5 operator. The system is not automated and will not recognize the operator change until it has been finalized.

The 30-day timeframe is consistent with Agency practice across all divisions.  The Notice of Violation letters are also viewable by the operator in the RRC Online Dashboard under the tab “Operator Letters Dashboard”.

A Facility Report must be sent to your electricity provider and confirmation of delivery must be sent to CID staff at [email protected] during each filing period.  

Once all facilities have been filed, a Facility Report can be generated in the Dashboard under the tab “Generate Filing Report”.

Please send the report to both the Retail provider and the Utility provider.  Please also remember to email proof of delivery to CID staff at [email protected]